Thursday, October 26, 2017 12:16:18 PM
flaflyersfan no trading of any stock is allowed during the SEC's suspension even on the Grey Market. However once the suspension is over the stock will open on the Grey Market. In HJOE'S case it was 2 days after the suspension was over that the SEC's administrative judge made their decision. So while it's true HJOE (opened) on the Grey Market after the 10 day suspension. Not a single share of HJOE traded on the Grey Market during that 2 days. 
How Long Do Trading Suspensions Typically Last?
The Securities Exchange Act of 1934 authorizes the SEC to suspend trading in a stock for up to ten business days.
What Happens After A Trading Suspension Ends?
When an SEC trading suspension ends, a broker-dealer may not solicit investors to buy or sell the previously-suspended stock until certain requirements are met. Before soliciting trades or resuming quotations in a stock that has been subject to a trading suspension, a broker-dealer must file a Form 211 with the Financial Industry Regulatory Authority (“FINRA”) representing that it has satisfied all applicable requirements, including those of Rule 15c2-11.
Among other things, Rule 15c2-11 requires broker-dealers to review and maintain certain documents and information about the company, including:
the corporation’s organization, operations, and control affiliates;
the nature of the securities outstanding and being traded; and
the issuer’s most recent balance sheet and its profit and loss and retained
earnings statement.
No broker-dealer may solicit or recommend that an investor buy shares in a stock that has been subject to a trading suspension unless and until FINRA has approved a Form 211 relating to the stock. If there are continuing regulatory concerns about the company, its disclosures, or other factors, such as a pending regulatory investigation, a Form 211 application may not be approved.
However, limited or “unsolicited” trading can occur in a stock that has been subject to a trading suspension after the suspension ends but before a Form 211 is approved. This may allow investors to trade the stock when a broker or adviser has not solicited or recommended such a transaction.
How Long Do Trading Suspensions Typically Last?
The Securities Exchange Act of 1934 authorizes the SEC to suspend trading in a stock for up to ten business days.
What Happens After A Trading Suspension Ends?
When an SEC trading suspension ends, a broker-dealer may not solicit investors to buy or sell the previously-suspended stock until certain requirements are met. Before soliciting trades or resuming quotations in a stock that has been subject to a trading suspension, a broker-dealer must file a Form 211 with the Financial Industry Regulatory Authority (“FINRA”) representing that it has satisfied all applicable requirements, including those of Rule 15c2-11.
Among other things, Rule 15c2-11 requires broker-dealers to review and maintain certain documents and information about the company, including:
the corporation’s organization, operations, and control affiliates;
the nature of the securities outstanding and being traded; and
the issuer’s most recent balance sheet and its profit and loss and retained
earnings statement.
No broker-dealer may solicit or recommend that an investor buy shares in a stock that has been subject to a trading suspension unless and until FINRA has approved a Form 211 relating to the stock. If there are continuing regulatory concerns about the company, its disclosures, or other factors, such as a pending regulatory investigation, a Form 211 application may not be approved.
However, limited or “unsolicited” trading can occur in a stock that has been subject to a trading suspension after the suspension ends but before a Form 211 is approved. This may allow investors to trade the stock when a broker or adviser has not solicited or recommended such a transaction.
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